{"id":"F2021L00007","name":"Statement of Principles concerning irritant contact dermatitis (Reasonable Hypothesis) (No. 3 of 2021)","slug":"statement-of-principles-concerning-irritant-contact-dermatitis-reasonable-hypothesis-no-3-of-2021","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":440732,"registerId":"F2021L00007-fast-fetch-1775956266524","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Statement of Principles concerning irritant contact dermatitis (Reasonable Hypothesis) (No. 3 of 2021)","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\nmeta-generator: Aspose.Words for .NET 20.2\n---\n\n?xml version=\"1.0\" encoding=\"utf-8\" standalone=\"no\"?>\n\n\n\n \n\nStatement of Principles\n\nconcerning\n\nIRRITANT CONTACT DERMATITIS (Reasonable Hypothesis)\n\n(No. 3 of 2021)\n\nThe Repatriation Medical Authority determines the following Statement of Principles under subsection 196B(2) of the Veterans' Entitlements Act 1986.\n\n \n\nDated 24 December 2020\n\n \n\n \n\n \n\n \n\n \n\n| The Common Seal of the Repatriation Medical Authority was affixed to this instrument at the direction of:
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Professor Nicholas Saunders AO
Chairperson
|\n\n\n \n\n \n\n\nContents\n\n1 Name\n\n2 Commencement\n\n3 Authority\n\n4 Repeal\n\n5 Application\n\n6 Definitions\n\n7 Kind of injury, disease or death to which this Statement of Principles relates\n\n8 Basis for determining the factors\n\n9 Factors that must exist\n\n10 Relationship to service\n\n11 Factors referring to an injury or disease covered by another Statement of Principles\n\nSchedule 1 - Dictionary\n\n1 Definitions\n\n \n\n\n\n\n1 Name\n\nThis is the Statement of Principles concerning irritant contact dermatitis (Reasonable Hypothesis) (No. 3 of 2021).\n\n2 Commencement\n\n This instrument commences on 25 January 2021.\n\n3 Authority\n\nThis instrument is made under subsection 196B(2) of the Veterans' Entitlements Act 1986.\n\n4 Repeal\n\nThe Statement of Principles concerning irritant contact dermatitis No. 110 of 2011 (Federal Register of Legislation No. F2011L01746) made under subsection 196B(2) of the VEA is repealed.\n\n5 Application\n\nThis instrument applies to a claim to which section 120A of the VEA or section 338 of the Military Rehabilitation and Compensation Act 2004 applies.\n\n6 Definitions\n\nThe terms defined in the Schedule 1 - Dictionary have the meaning given when used in this instrument.\n\n7 Kind of injury, disease or death to which this Statement of Principles relates\n\n(1) This Statement of Principles is about irritant contact dermatitis and death from irritant contact dermatitis.\n\nMeaning of irritant contact dermatitis\n\n(2) For the purposes of this Statement of Principles, irritant contact dermatitis:\n\n(a) means inflammation of an area of the skin from exposure to an irritant that has been applied to the same area of skin; and\n\n(b) involves direct tissue injury; and\n\n(c) includes irritant contact dermatitis that is due to cutaneous exposure from airborne irritants; and\n\n(d) excludes:\n\n(i) allergic contact dermatitis;\n\n(ii) atopic dermatitis (eczema);\n\n(iii) dermatitis due to extremes of weather, friction, solar radiation or other forms of radiation;\n\n(iv) photocontact dermatitis;\n\n(v) systemic allergic dermatitis; and \n\n(vi) urticaria.\n\nNote: Irritant contact dermatitis typically presents as a well-demarcated red rash in an area of skin that has come into contact with an irritant. It may be acute, with swelling and blistering of affected skin or chronic, with dryness, scaling, thickening or fissuring of affected skin. Irritant contact dermatitis can affect the skin of the eyelids and surrounding the mouth.\n\n(3) While irritant contact dermatitis attracts ICD‑10‑AM code L22 or L24, in applying this Statement of Principles the meaning of irritant contact dermatitis is that given in subsection (2).\n\n(4) For subsection (3), a reference to an ICD-10-AM code is a reference to the code assigned to a particular kind of injury or disease in The International Statistical Classification of Diseases and Related Health Problems, Tenth Revision, Australian Modification (ICD-10-AM), Tenth Edition, effective date of 1 July 2017, copyrighted by the Independent Hospital Pricing Authority, ISBN 978-1-76007-296-4.\n\nDeath from irritant contact dermatitis\n\n(5) For the purposes of this Statement of Principles, irritant contact dermatitis, in relation to a person, includes death from a terminal event or condition that was contributed to by the person's irritant contact dermatitis.\n\nNote: terminal event is defined in the Schedule 1 - Dictionary.\n\n8 Basis for determining the factors\n\nThe Repatriation Medical Authority is of the view that there is sound medical‑scientific evidence that indicates that irritant contact dermatitis and death from irritant contact dermatitis can be related to relevant service rendered by veterans, members of Peacekeeping Forces, or members of the Forces under the VEA, or members under the MRCA.\n\nNote: MRCA, relevant service and VEA are defined in the Schedule 1 - Dictionary.\n\n9 Factors that must exist\n\nAt least one of the following factors must as a minimum exist before it can be said that a reasonable hypothesis has been raised connecting irritant contact dermatitis or death from irritant contact dermatitis with the circumstances of a person's relevant service:\n\n(1) having the affected area of skin exposed to an irritant within the three days before the clinical onset of irritant contact dermatitis;\n\nNote 1: irritant is defined in the Schedule 1 - Dictionary. \n\nNote 2: Activities involving prolonged or frequent contact with water or other liquids (wet work) are a common cause of irritant contact dermatitis. Such activities include frequent hand washing, handling wet things and prolonged wearing of occlusive gloves.\n\n(2) having the affected area of skin exposed to an irritant within the three days before the clinical worsening of irritant contact dermatitis;\n\nNote 1: irritant is defined in the Schedule 1 - Dictionary. \n\nNote 2: Activities involving prolonged or frequent contact with water or other liquids (wet work) are a common cause of irritant contact dermatitis. Such activities include frequent hand washing, handling wet things and prolonged wearing of occlusive gloves.\n\n(3) inability to obtain appropriate clinical management for irritant contact dermatitis.\n\n10 Relationship to service\n\n(1) The existence in a person of any factor referred to in section 9, must be related to the relevant service rendered by the person.\n\n(2) The factors set out in subsections 9(2) to 9(3) apply only to material contribution to, or aggravation of, irritant contact dermatitis where the person's irritant contact dermatitis was suffered or contracted before or during (but did not arise out of) the person's relevant service.\n\n11 Factors referring to an injury or disease covered by another Statement of Principles\n\nIn this Statement of Principles:\n\n(1) if a factor referred to in section 9 applies in relation to a person; and\n\n(2) that factor refers to an injury or disease in respect of which a Statement of Principles has been determined under subsection 196B(2) of the VEA;\n\nthen the factors in that Statement of Principles apply in accordance with the terms of that Statement of Principles as in force from time to time.\n\n \n\n \n\nSchedule 1 - Dictionary \n\nNote: See Section 6\n\n1 Definitions\n\nIn this instrument:\n\n irritant means a chemical substance or physical agent which, when it comes into contact with an area of skin, is capable of producing direct tissue injury and inflammation. It does not include heat, cold, friction, solar radiation or other forms of radiation. Examples of irritants include:\n\n(a) cleansers (including soap and alcohol based hand rubs);\n\n(b) detergents (including sodium lauryl sulphate);\n\n(c) oils and coolants;\n\n(d) fuels;\n\n(e) solvents;\n\n(f) food (including citrus fruits);\n\n(g) alkalis (including wet cement or lime);\n\n(h) pesticides (including insect repellent);\n\n(i) adhesives (including epoxy resins);\n\n(j) tear gas or smokescreens;\n\n(k) fibreglass;\n\n(l) plant sap (including spurge);\n\n(m) bodily fluids of the rove beetle; and\n\n(n) urine or faecal incontinence.\n\n irritant contact dermatitis—see subsection 7(2).\n\n MRCA means the Military Rehabilitation and Compensation Act 2004.\n\n relevant service means:\n\n(a) operational service under the VEA;\n\n(b) peacekeeping service under the VEA;\n\n(c) hazardous service under the VEA;\n\n(d) British nuclear test defence service under the VEA;\n\n(e) warlike service under the MRCA; or\n\n(f) non-warlike service under the MRCA.\n\nNote: MRCA and VEA are also defined in the Schedule 1 - Dictionary.\n\n terminal event means the proximate or ultimate cause of death and includes the following:\n\n(a) pneumonia;\n\n(b) respiratory failure;\n\n(c) cardiac arrest;\n\n(d) circulatory failure; or\n\n(e) cessation of brain function.\n\n VEA means the Veterans' Entitlements Act 1986.\n\n \n\n \n","sortOrder":0}],"analysis":{"kimi_summary":{"content_quality":"ok","complexity_score":3,"scope_assessment":{"changed":false,"description":"This instrument maintains the same narrow scope as its 2011 predecessor and the standard template for Repatriation Medical Authority Statements of Principles. It addresses only irritant contact dermatitis in the context of veterans' compensation, with no expansion into broader occupational health or civilian contexts."},"complexity_factors":["Short, focused instrument (approximately 1,500 words)","Only 7 defined terms in the Dictionary (irritant, irritant contact dermatitis, MRCA, relevant service, terminal event, VEA)","Simple conditional structure: 'at least one of the following factors must exist'","Clear 3-day temporal windows for exposure (no complex calculations)","Single cross-reference mechanism (section 11 links to other Statements of Principles)","Straightforward exclusion list in section 7(2) specifying what is NOT covered","No nested exceptions or layered conditional logic"],"plain_english_summary":"This is a **Statement of Principles** (a legal instrument that sets medical rules for compensation claims) about **irritant contact dermatitis** — a type of skin inflammation caused by exposure to irritating substances like chemicals, detergents, or bodily fluids.\n\n**What it does:**\n- It establishes the medical criteria that must be met for a veteran or defence force member to claim compensation for irritant contact dermatitis (or death from it) under Australia's veterans' compensation schemes.\n- It replaces an earlier 2011 version of the same rules.\n\n**Who it affects:**\n- Current and former Australian Defence Force members\n- Veterans claiming under the *Veterans' Entitlements Act 1986* or the *Military Rehabilitation and Compensation Act 2004*\n\n**How compensation works under this instrument:**\nTo successfully claim, a person must show **at least one** of these factors:\n1. **Exposure before onset:** The affected skin was exposed to an irritant within 3 days before the skin condition first appeared; **OR**\n2. **Exposure before worsening:** The affected skin was exposed to an irritant within 3 days before the condition got worse; **OR**\n3. **Lack of medical care:** The person couldn't get appropriate medical treatment for the condition.\n\n**Important limitations:**\n- The exposure or lack of treatment must be connected to the person's military service (operational service, peacekeeping, hazardous service, etc.)\n- This only covers \"irritant\" dermatitis (direct chemical/physical damage to skin), **not** allergic reactions, eczema, sun damage, or rashes from heat/cold\n- \"Wet work\" (frequent hand washing, handling wet items, wearing gloves) counts as exposure to irritants\n\n**Why it matters:**\nThis document determines whether a veteran's skin condition \"counts\" as service-related for compensation purposes. It sets a relatively low threshold (just 3 days of exposure) but requires a direct causal link to service activities."},"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":true,"description":"This instrument expressly repeals the 2011 Statement (section 4) and replaces it with updated criteria. It clarifies the meaning of irritant contact dermatitis (section 7(2)), expressly includes cutaneous exposure from airborne irritants (section 7(2)(c)), lists specific examples of irritants (Schedule 1), and extends coverage to death contributed to by the condition (section 7(5)). These textual changes indicate an amended scope and refined definitional and causal rules for assessing claims under the VEA and MRCA."},"complexity_factors":["Technical medical definitions and exclusions (subsection 7(2); Schedule 1) increase interpretive complexity for non‑medical decision makers.","Strict temporal causation thresholds: exposure within three days before clinical onset or worsening (section 9(1)–(2)) require precise event timing in claims.","Extension to death via contribution to a terminal event (section 7(5); terminal event defined in Schedule 1) adds causal chain complexity.","Requirement that any relevant factor be tied to 'relevant service' (section 10(1)) imposes a legal nexus to service type (Schedule 1 definitions of relevant service).","Different treatment of material contribution or aggravation where the condition pre‑existed service (section 10(2)) creates an evidentiary distinction.","Interaction with other Statements of Principles (section 11) requires cross‑reference and may shift applicable factors.","Broad but specific list of example irritants (Schedule 1) requires factual matching of exposures to listed items.","Burden to show 'inability to obtain appropriate clinical management' (section 9(3)) is fact‑intensive and potentially hard to prove.","Instrumental role of the Repatriation Medical Authority and reliance on its medical‑scientific view (section 3; section 8) centralises interpretive authority.","Legal applicability limited to VEA/MRCA claim processes (section 5) — administrative law and claims procedure context matters for implementation."],"plain_english_summary":"Replaces the 2011 Statement and sets the medical criteria for linking irritant contact dermatitis (and death from it) to a person’s relevant service under the VEA and MRCA. It defines what counts as irritant contact dermatitis, lists common irritants, gives timing rules (typically exposure within three days before clinical onset or worsening) and requires the factors to be related to service.\n\nIt affects veterans and service members claiming entitlement and matters because it determines the medical threshold and evidentiary features that must be met for a compensable claim."},"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"summary":{"content_quality":"ok","complexity_score":1,"scope_assessment":{"changed":true,"description":"This instrument repeals and replaces the Statement of Principles concerning irritant contact dermatitis No. 110 of 2011, updating the factors that can link the condition to service for claims made from 25 January 2021."},"complexity_factors":["Medical definition with exclusions and time-specific exposure windows","Narrow application to veterans' compensation claims under specific legislation","Relies on separately defined terms from the Veterans' Entitlements Act and Military Rehabilitation and Compensation Act"],"plain_english_summary":"This Statement of Principles tells when irritant contact dermatitis (or death from it) can be reasonably linked to military or peacekeeping service for veterans’ compensation. It affects current/former ADF and related claimants and says the condition must be explained by recent exposure to an irritant, a service-related worsening, or lack of appropriate treatment due to service. Allergic reactions and other non‑irritant skin disorders are excluded."}},"importantCases":[],"_links":{"self":"/api/acts/statement-of-principles-concerning-irritant-contact-dermatitis-reasonable-hypothesis-no-3-of-2021","history":"/api/acts/statement-of-principles-concerning-irritant-contact-dermatitis-reasonable-hypothesis-no-3-of-2021/history","analysis":"/api/acts/statement-of-principles-concerning-irritant-contact-dermatitis-reasonable-hypothesis-no-3-of-2021/analysis","conflicts":"/api/acts/statement-of-principles-concerning-irritant-contact-dermatitis-reasonable-hypothesis-no-3-of-2021/conflicts","importantCases":"/api/acts/statement-of-principles-concerning-irritant-contact-dermatitis-reasonable-hypothesis-no-3-of-2021/important-cases","documents":"/api/acts/statement-of-principles-concerning-irritant-contact-dermatitis-reasonable-hypothesis-no-3-of-2021/documents"}}